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Privacy Policy

Privacy Policy

This Privacy Policy sets the rules for storing and accessing data on Users’ Devices who use the Service for the purpose of providing electronic services by the Administrator, as well as the rules for collecting and processing personal data of Users, which have been provided by them personally and voluntarily through tools available in the Service.

§1 Definitions

  • Service – the “dotGrow” online service operating at https://dotgrow.net.
  • External Service – online services of partners, service providers, or contractors cooperating with the Administrator.
  • Service/Data Administrator – the Service Administrator and the Data Administrator (hereinafter referred to as the Administrator) is the company “dotGrow Daniel Andraszewski”, operating at: ul. Korzona 113/71, Warsaw, 03-571 Poland, with the tax identification number (VAT ID): PL5242679498, providing electronic services via the Service.
  • User – an individual for whom the Administrator provides services electronically via the Service.
  • Device – an electronic device with software through which the User gains access to the Service.
  • Cookies – text data collected in the form of files placed on the User’s Device.
  • GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons concerning the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation).
  • Personal Data – means information about an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, online identifier, or one or more specific factors related to physical, physiological, genetic, mental, economic, cultural, or social identity.
  • Processing – means an operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collecting, recording, organising, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, disseminating or otherwise making available, aligning or combining, restricting, erasing or destroying.
  • Restriction of processing – means the marking of stored personal data to limit their future processing.
  • Profiling – means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to an individual, particularly to analyse or predict aspects concerning the performance, economic situation, health, personal preferences, interests, reliability, behaviour, location, or movements of that individual.
  • Consent – consent of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
  • Personal data breach – means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored, or otherwise processed.
  • Pseudonymisation – means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
  • Anonymisation – anonymisation of data is an irreversible process of operations on data that destroys or overwrites “personal data” making it impossible to identify or link a record with a specific user or natural person.

§2 Data Protection Officer

Pursuant to Art. 37 of the GDPR, the Administrator has not appointed a Data Protection Officer. For matters concerning the processing of data, including personal data, please contact the Administrator directly.

§3 Types of Cookies

  • Internal Cookies – files placed and read from the User’s Device by the Service’s telecommunication system.
  • External Cookies – files placed and read from the User’s Device by telecommunication systems of External Services. The scripts of External Services that may place Cookies on the User’s Device have been intentionally embedded in the Service through scripts and services made available and installed in the Service.
  • Session Cookies – files placed and read from the User’s Device by the Service during a single session of the Device. After the session ends, the files are deleted from the User’s Device.
  • Persistent Cookies – files placed and read from the User’s Device by the Service until they are manually deleted. These files are not deleted automatically after the Device’s session ends unless the User’s Device configuration is set to remove Cookies after the session ends.

§4 Data Storage Security

  • Mechanisms for storing and reading Cookie files – The mechanisms for storing, reading, and exchanging data between Cookie files saved on the User’s Device and the Service are implemented through built-in mechanisms of web browsers and do not allow the retrieval of other data from the User’s Device or data from other websites that the User has visited, including personal data or confidential information. Transferring viruses, trojans, or other worms to the User’s Device is also practically impossible.
  • Internal Cookies – Cookies used by the Administrator are safe for Users’ Devices and do not contain scripts, content, or information that could endanger the security of personal data or the security of the Device used by the User.
  • External Cookies – The Administrator takes all possible measures to verify and select service partners in the context of Users’ security. The Administrator cooperates with reputable, well-known partners of global trust. However, the Administrator does not have full control over the content of Cookies from external partners. Therefore, as much as the law allows, the Administrator is not responsible for the security, content, or lawful use of Cookies from External Services installed through scripts embedded in the Service.
  • Control of Cookie Files – Users can, at any time, independently change their settings for saving, deleting, and accessing the data saved in Cookie files by each website. Instructions on how to disable Cookies in the most popular desktop browsers are available on the following sites:
  • User Side Risks – The Administrator uses all possible technical measures to ensure the security of data placed in Cookie files. However, it should be noted that the security of these data depends on both sides, including the User’s activities. The Administrator is not responsible for interception, session impersonation, or deletion of these data as a result of intentional or unintentional User activity, viruses, trojans, or other spyware that may or has infected the User’s Device. To secure against these threats, Users should follow the guidelines for safe Internet usage.
  • Personal Data Storage – The Administrator ensures that every effort is made to keep personal data voluntarily entered by Users secure, restrict access, and process it in line with its intended purpose. The Administrator also ensures every effort to secure stored data from loss through the application of appropriate physical and organisational safeguards.

§5 Purposes for Which Cookies Are Used

  • Enhancing and facilitating access to the Service
  • Personalising the Service for Users
  • Marketing and remarketing on external platforms
  • Advertising services
  • Affiliate services
  • Conducting statistics (user counts, number of visits, types of devices, connections, etc.)
  • Providing multimedia services
  • Offering social networking services

§6 Purposes of Personal Data Processing

Personal data voluntarily provided by Users is processed for one of the following purposes:

  • Provision of electronic services:
    • Handling enquiries via the contact form
    • Services for sharing information about content placed on the Service across social media or other websites
  • Communication between the Administrator and Users regarding matters related to the Service and data protection
  • Ensuring the legitimate interests of the Administrator

Data about Users collected anonymously and automatically is processed for one of the following purposes:

  • Conducting statistics
  • Remarketing
  • Serving advertisements tailored to Users’ preferences
  • Managing affiliate programmes
  • Ensuring the legitimate interests of the Administrator

§7 Cookies from External Services

The Administrator uses JavaScript scripts and web components from partners on the Service, who may place their own cookies on the User’s Device. Below is a list of partners or their services implemented on the Service that may place cookies:

§8 Types of Data Collected

The Service collects data about Users. Anonymous data collected automatically:

  • IP address, Browser type, Screen resolution, Approximate location, Pages viewed, Time spent, Operating system, Previous page address, Referring site, Browser language, Connection speed, ISP, Demographic data (age, gender).

Data collected when subscribing to the Newsletter service:

  • Name / pseudonym, Email address, IP address (collected automatically).

§9 Access to Personal Data by Third Parties

As a rule, the sole recipient of personal data provided by Users is the Administrator. Access to the data may be granted to entities responsible for maintaining the infrastructure, such as:

§10 Method of Processing Personal Data

  • Personal data will not be transferred outside the European Union unless published by the User (e.g., in comments).
  • Personal data will not be used for automated decision-making (profiling).
  • Personal data will not be sold to third parties.

The Service collects and processes User data based on:

  • Regulation (EU) 2016/679 (GDPR), Art. 6(1)(a) (consent), (b) (contract), (f) (legitimate interest).
  • Act of 10 May 2018 on the Protection of Personal Data (Poland).

§12 Duration of Processing Personal Data

As a general rule, personal data is retained solely for the duration of the Service provided. Data is deleted or anonymised within 30 days from the conclusion of service. Exception: situations requiring securing the legitimate interests of the Administrator (up to 3 years in case of breach).

Users have the right to:

  • Access, Rectification, Deletion, Restriction of processing, Data Portability, Object to processing, Lodge a complaint with a supervisory authority.

§14 Contacting the Administrator

You can contact the Administrator in one of the following ways:

§15 Service Requirements

Limiting cookies may cause some functions of the Service to malfunction. The Administrator is not responsible for such malfunctioning features.

The Service may contain links to external websites. The Administrator is not responsible for the content or security of those sites.

§17 Changes to the Privacy Policy

The Administrator reserves the right to change this Privacy Policy at any time. Changes will be published on this subpage and come into effect upon publication.